Client Personal Data Statement
Simmons Bridgman Associates is a specialist career transition consultancy focused on managing personal and company career transitions.
This document explains how we use the personal data we collect about you when you access a service or undertake a programme with us.
When you undertake a programme directly with us you sign a letter of engagement, confirming our obligations to each other.
When your programme is commissioned by a third party organisation our obligations to handle your data appropriately remain exactly the same.
Following your engagement with us it will be necessary and in our legitimate interest to process your personal data in the manner set out below:
What information do we collect about you?
We collect personal data about you when you engage our services. That personal data is needed to provide you with the programmes and services we deliver.
Personal information that we’ll process in connection with all of our programmes and services, if relevant, includes:
• Personal and contact details, such as title, full name, contact details and contact details history
• Your date of birth, and/or age (if you have provided us with this),
• Your nationality, if needed for the service you are receiving
• Family members, if relevant to the service you are receiving
• Records of your contact with us such as via your phone number and, if you get in touch with us online, your email address
• Products and services you use with us, and the associated payment methods used
• Information we obtained from third parties, including information about the service we have to provide on their behalf and your personal information
• Financial details about you, such as your salary and details of other income, details of your expenditure that you feel are appropriate to share with us as part of your programme.
• Information about your employment status.
• Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK
• Your marital status, family, lifestyle or social circumstances that you feel are appropriate to share with us as part of your programme.
• Insights about you and our customers gained from analysis or profiling of customers
• Third party transactions; such as when a person or organisation, other than you, pays for the service or programme that you are receiving
• Marketing to you and data analysis, including history of those communications and whether you attend an event. We may also analyse data to help target events that we think are relevant to you.
What do we do with your personal data?
We use your personal data for any of the following purposes:
• Assessing an application for a programme or service, including considering whether or not to offer you the programme or service, the price, the risk of doing so, agreeing appropriate payment method and terms
• Managing programmes and services relating to that the programme or service, or application for one
• Updating your record, tracing your whereabouts to recover debt
• Managing any aspect of the programme or service we provide to you
• To perform and/or test the performance of, our programmes, services and internal processes
• To improve the operation of our business and that of our third party referrers
• To follow guidance and best practice under the change to rules of governmental and regulatory bodies
• For management and auditing of our business operations including accounting
• To monitor and to keep records of our communications with you.
• To administer our good governance requirements
• For market research, analysis and to produce statistics
• For direct marketing communications and related profiling to help us to offer you relevant programmes and services, including deciding whether or not to offer you certain programmes and service. We may send information to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match). Offers may relate to any of our programmes and services.
• To develop new programmes and services and to review and improve current programmes and services
• To comply with legal and regulatory obligations, requirements and guidance
• To provide insight and analysis of our clients both for ourselves and for the benefit of the third party who is funding your programme, either as part of providing programmes or services, helping us improve programmes or services, or to assess or improve the operating of our businesses
• To share information, as needed, with third party referrers or as part of providing and administering our programmes and services, or operating our business
• To facilitate the sale of one or more parts of our business
Do you have to provide your personal information to us?
We’re unable to provide you with our programmes or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.
How long do we keep your data?
We will keep your personal data only for as long as is necessary. This is generally six months from when you complete your programme unless otherwise agreed. Our goal is to provide you with useful career transition coaching services for the whole of your career. However, you retain control over your personal data and may instruct us to delete your data at any time. When instructed by you, we will remove your personal data from our databases unless we are required to keep it for legal reasons.
What is our lawful basis for processing your data?
We have a legitimate interest in processing your data in order to provide you with the programmes or service as outlined above.
What are your rights under data protection laws?
Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances.
• The right to be informed about the processing of your personal information.
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the “right to be forgotten”)
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information (“data portability”)
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
Your right to object
You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact section of our website to exercise these rights. You also have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/ .
We will only ever send you information which relates to your programme and is relevant to you.
You can opt out of receiving communications from us at any time by using the links included in the emails you receive from us.
We do not collection information about your computer or general internet usage.
Data Sharing and Transfers
We do not share your personal data with third parties, except where it is necessary to do so in order to provide your programme as described above.
Your personal data is stored on servers in the European Economic Area only.
What should you do if your personal information changes
You should tell us so that we can update our records using the details in the Contact section of our website. We’ll then update your records if we can.
Changes to our Personal Data Statement
We keep this document under regular review and we place any updates on this webpage. This statement was last updated on 6th April 2021.
If you have any questions about this privacy notice, or if you wish to exercise your rights, you can contact us by going to the Contact section of our website. Alternatively, you can write to Simmons Bridgman Associates, 38 Clermiston Place, Edinburgh, EH4 7DR marking it for the attention of the Data Controller.